EM Coding Alert

Reader Question:

Don't Assume ICU Means Critical Care

Question: My physician often rounds on patients in the intensive care unit (ICU). He feels that because the patient is in critical condition and in the ICU, he should be able to bill critical care codes for these encounters. I disagree. Can you please clarify when we can report critical care codes?

Pennsylvania Subscriber

Answer: You are correct. You cannot bill the critical care codes 99291 (Critical care, evaluation and management of the critically ill or critically injured patient; first 30-74 minutes) and 99292 (... each additional 30 minutes [List separately in addition to code for primary service]) simply because the place of service is the ICU.

Here’s why: Critical care is not location based — the term describes a type of care. The physician must meet three criteria before billing for critical care:

  • The patient must have a critical illness or injury (usually defined as a critical organ system failure or a shock-like syndrome with a high probability of imminent or life threatening deterioration in the patient's condition)
  • The physician must document at least 30 minutes of time spent directly with the patient or in the hospital unit, limited only to that patient
  • The physician must document highly complex decision making to assess, manipulate, and support vital system function(s) to treat the critical illness or to prevent further deterioration of the patient's condition.

Better option: If your physician evaluates a patient in the ICU but does not perform critical care services, you’ll report an initial hospital care code such as 99221 (Initial hospital care, per day, for the evaluation and management of a patient ...) or an appropriate subsequent hospital care code (99231-99233).